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Sevenoaks Local Plan - the Comments

Hartley-Kent: The Website for Hartley
Sevenoaks have apparently logged all the letters now and there are 1,716 letters listed but 105 were multiple comments from the same person, making 1,611 individuals or 1,807 if you count the total number of signatories (some letters were from more than on e person).  Local SDC councillors say 10% of all replies were about Corinthian.  

I have counted 77 supportive comments (for all or part of the development) and 1,530 against all or part.  There are 4 neutral comments .  Included in the figures are 20 doubtful ones (4 for, 16 against) where a full name has not been given, and therefore they might be rejected as anonymous.  

A thousand plus objections sounds impressive, but in an area of nearly 20,000 people it is barely 10% of people objecting to something described as an existential threat to the whole area.  I suspect the promoters may say that means 90% don't mind (politicians are fond of doing this when it their proposals that are controversial).  Maybe it is early days or just not the way things are done locally, but in other areas with contentious plans you would expect every other house to display a poster objecting.

Needless to say I haven't got anywhere near reading them all (although many were very similar and based on the No Hartley Expansion template).  Some consultees carry more weight, so I have outlined their comments below.

1.  Kent County Council
Their reply is neutral but have set out the areas that need to be considered from their point of view.  I suspect the developer can meet the education requirements either on site or by Section 106 contribution, however it is clear they will need a lot more work on highway capacity issues, to meet the requirements of the county council.

  • Secondary Schools: they will not support development in Swanley, Hextable and Hartley unless an 8 form entry school is built, preferably at Pedham Place (not currently proposed)
  • Primary Schools: they estimate it will result in 264 additional primary school pupils or 1.2 form entry if this and the other sites locally were built upon (942 houses).  They appear to say that a combination of the additional form entry for Hartley Primary school at Corinthian and some additional capacity in the other local schools would be sufficient.  They do say the developers can't count on getting any of the windfall funds from the disposal of the existing Hartley and Milestone school sites which are owned by the council.
  • Archaeology: most the site they don't think will be an issue but they require careful treatment of the land around Pennis House.
  • Highways: The council have 3 categories for assessments - A (met), B (potential to meet), C (difficult to meet).  They say a full Transport Assessment will be required for a site this big.  The main access they say should be from Ash Road, which is better suited to take the traffic.  Overall they score access a "B", but capacity a "C".  
  • Sustainability: they have three sustainability criteria (1) within ½ mile of bus or train with 2 services per hour, (2) within ½ mile walk of convenience store, GP surgery and primary school, (3) within ½ hour by pubic transport of GP Surgery, hospital, employment, schools and major shopping centre.  An "A" ranking means all three are met, "B" is one or two, "C" is none.  They class Corinthian as "B", and note that bus, cycling and foot connections to Longfield can be provided.

2.  Thames Water
Thames Water handles this area's sewerage.

They are neutral on the issue of the proposals but say the Developer will have to discuss the drainage requirements with them before proceeding.  They also stress the need for any development to minimise surface water run off and preferably to avoid this entering the public drainage system.

3.  Other Utilities
No reply from South East Water or Gas/Electricity suppliers.  However previously published documents by them suggest that they are unlikely to object but to spell out their requirements to the Developer in terms of providing the infrastructure required.

4.  Hartley Parish Council
They paid Bryian Jezeph Consultancy Limited to write their reply.

A lot of what they say hinges on their interpretation of the terms "exceptional circumstances" and "infrastructure needs".  They have chosen to believe that exceptional circumstances do not apply if the infrastructure offered is not essential.  However Policy 1 of the draft District Plan would appear to say that the need to meet the housing target is the exceptional circumstances, and the infrastructure proposals are a means of deciding which are the best ones to adopt.

(a) They say development should be by extension to existing towns.  If not they say a garden village should be built without saying where.
(b) They say the site should not be developed in case Dartford Council agree to take some of Sevenoaks's housing allocation.  This seems unlikely given statements made by the Dartford Council portfolio holder last year.
(c) They query why some brownfield land sites were rejected for housing.
(d) The parish council to say (para 2.3) they will support other sites in Hartley now instead - at Chapelwood Enterprise Park (15-20 houses), Grosvenor Church Road (18-25), Olinda Ash Road (27-37), Park House Church Road (7-10)
(e) Not much evidence of the "needs" that infrastructure improvements are supposed to meet.  They claim the Developer of Corinthians has not said the infrastructure proposed is essential.  I suppose this depends on what the local plan means by "addressing evidenced infrastructure needs", the parish council claim this means "existing" needs, but it is not clear from the draft district plan that this is what is meant.  A lot of what Hartley PC says is based on this assumption:
(i) Retirement housing - the council skates around the need for this locally, simply claiming Corinthian is too isolated.  
(ii) Health Centre - the council quote rather selectively from the Jubilee Practice press release, which says that, if done properly, this could meet a need for longer opening hours in the area.
(iii) Sports - the council points out that other facilities already exist locally, however I understand some of the offering is not provided for at present.
(iv) School - the council raise the question of who is going to build the site, the developer or someone else?  As there is slight surplus of places at present, the council say that the developer cannot claim exceptional circumstances.
(v) Employment - Hartley PC has for many years had an aversion to commercial use of land, so it is perhaps not surprising they can percieve no need for it.

The parish council appear to have given little consideration to the issue of local need for affordable housing.

5.  Council for the Protection of Rural England
They object on the grounds that the Green Belt in Sevenoaks is mostly "strongly performing" (although Sevenoaks claims the Corinthian area is not), and it would lead to the coalescence of settlements and is out of proportion to the existing Fawkham settlement.  They add that they think the proposed infrastructure improvements are only required by new housing and it would cause traffic problems.

6.  Ash Parish Council
The more southerly parish looks at things from a slightly different angle, as they raise the issue of possible extra traffic on the narrow South Ash Road to the A20.  They are particularly concerned with the plans to move Milestone School which they say the county council has spent £10m improving.  This would entail the loss of the school's shared facilities with the Parish Council, including tennis courts, sports hall and the parish office.  If the school closes the site will become housing they say.

Selected Comments
Around 1 million words have been written about the proposals.  I have not had the opportunity to read more than a fraction, but here are a selection of comments which I thought make their points (for or against) well.

"Over many years I have fought long and hard over literally a square metre of building on Green belt land .... often in ludicrous circumstances only to be confronted with the greatest objection from Sevenoaks planning department. It is with considerable incredulity that I find the same Council that appeared to be fighting to save green belt land is now even considering this proposal..... This area of Kent is fast becoming a suburb of London and a quick glance at the light pollution seen from vantage points such as the Queen Elizabeth bridge verify this ever increasing and meandering built environment polluting this once green and pleasant land....This application should be refused and the Planning department should not allow either Government or commercial pressure to persuade them to make a wrong decision to approve this application which the Parish Council is also against which will have an adverse effect on this area and future generations long into the future."

"The planning mistake that resulted in New Ash Green has already caused enough problems.... The proposed road to alleviate traffic problems was not constructed, except for the section past the Royal Oak public house, which is of little help to Hartley residents. "Muddle through" seems to have been the system. It appears that we could shortly be faced with another dose of the same problems. Whether or not on the same scale we cannot say, but when services are running at full capacity, any significant extra demand is too great. We can understand the major problem faced by our District Council; it is one of providing numerous homes, not necessarily homes which are compatible with those nearby.....We believe that Hartley has tolerated more than enough major development."

"This proposal is the largest and most egregious example of cunning gradualism that there is. This land has been, in the past, turned into amenity land and the purpose of the amenity land (a golf course) is to duplicate another nearby facility to which this facility has ties. Many local people believe that this has been done to game the green-belt rules. Although there is a significant housing need within the south of England, Green Belt rules exist for a reason and a significant housing need across half a country cannot be considered "exceptional circumstances" if the Green Belt is to mean anything at all.... These sites should be retained as green space, as they are part of the Green Belt. If not as a sports facility, then for agriculture."

"I support this proposal, please start listening to the next generation and not those who are currently happy as they were able to benefit the previous Hartley expansion- these people will probably not see all the benefits and don't care about the opportunities for the next generation. This provides the next generation the chance to have access to better GP provision, state of the art school facilities, excellent sports provision and access to a safe park. Most of all this will provide much needed affordable housing in an area that needs it most. Please support these plans! "

"Whilst there may be some case to be made for supply of a limited number of new affordable dwellings in the area, along with extra accommodation for the elderly, I am not convinced that the proposals MX52 and MX53 justify building on green belt land, given the Council's published criteria for release of such land. From the information so far supplied and the lack of promises of any enforceable covenants relating to aspects of the developers' proposals, it is not easy to understand how the hypothetical new dwellings would be integrated to the existing communities. For example: how will the Council ensure that the proportion of affordable homes will be delivered; will adequate infrastructure be provided; who will bear the cost of operating the proposed facilities; will there be adequate parking, etc.? A ca. 30% increase in the population will bring a far larger increase in the number of cars using the roads – and modern cars are larger than those accommodate in the past. The criteria used to provide for vehicles in past developments are now inadequate in the extreme. An evening stroll around the 50-year old development New Ash Green reveals access roads clogged by parked vehicles, blocking access by emergency services. This is due to the original inadequate number of garages and parking spaces and to the size of modern passenger cars. What assurance do we have that the plans consider such developments and the likely obsolescence of rules of thumb for planning for modern numbers and dimensions of cars. School car parks alone have trebled in size in recent decades at all local schools due to the number of ancillary staff employed, and yet fail to provide space for the occasional visitor. The footprint of any new educational development must be properly assessed – perhaps at the expense of numbers of dwellings. In the absence of new dwellings, the need for any expansion of schools is not demonstrated and, apart from Milestone School which has a wide catchment area, the suggested location is not convenient for existing residents, leading to a probability of deliveries of pupils by car. In the case of Milestone, the particular needs of pupils result in a considerable queue of taxis and minibuses at the start and end of the school day: has sufficient space for these been assured, or will access roads become blocked? The suggestion that there is an “opportunity” to provide such facilities does not indicate the adequacy of such potential provisions - and without binding assurance from developers their eventual emergence cannot be guaranteed. No proposal has been made for re-use of existing school sites, in the event of replacement. One may reasonably assume that these will be filled with additional housing, so adding to the stresses upon amenities that are already indicated in objections to the current proposals. The developers fail to comment upon the unimpeded country views that are seen from public footpaths alongside or traversing the proposed developments. The proposed provision of a “Country Park” (on ground that is already vacant) at the extreme edge of one sector does notreally compensate for blocking these views with dwellings! In this era of austerity, for the proposal to be taken seriously, either developers of the District Council must ensure that the running costs of such a development are covered from the start and into the future. It is not apparent that “New areas of woodland and open spaces, greens and planting” are really needed “to enhance biodiversity”, but rather that these may go some way towards mitigating the loss of greenery and biodiversity that will be created by the new suggested houses and other facilities. Current water supplies come from relatively local boreholes and sewage probably leaves the area towards the Thames near Dartford. Have the developers considered who, other than consumers, will pay for necessary upgrades to bring in extra water and treat effluent? Proposals for transport appear inadequate. A new development will bring more vehicles both driving through existing roads and seeking to park near shops and Longfield railway station, where provision is already stressed. Any developer should be obliged to provide significant enhancements at the outset, whatever the cost entailed. Only a slight increase in traffic on Fawkham Valley Road could have fatal consequences for pedestrians, especially at the restricted-width railway arch at Longfield. Properly costed and resourced plans are needed, and if all other inadequacies are catered for, one wonders if the development will still be classed as viable. And if the quota of affordable dwellings will be realised. Whilst vehicles are becoming less polluting, the spread of pollution from micro-particulates deposited on and near carriageways remains, and will increase with more road usage. The releases from wear and tear on items such as brake pads involve chemical compounds of particular concern. The suggestion that an “8 till 8” GP facility might be viable seems unfounded. It is not known to feature in any current NHS plan, and the current practitioners struggle to recruit and retain staff. The comment in the developer's brochure that “Numerous bus routes serve Hartley and Longfield” is totally misleading, and leads one to wonder about the level of care exercised in producing that brochure! On any day of the week only two bus routes serve Hartley, and timetable cuts and unreliability render these far from useful to workers. Incidentally, none of the routes serve Sevenoaks, but take passengers away from the District to earn and spend money in the territory of neighbouring local authorities. I am sure that there are superior options for the Council to consider, and note that comment is made in the Council's SHELAA about knowledge of housing plans in the areas of Tonbridge and Tunbridge Wells, no mention is made of the Gravesham and Dartford areas, which include Ebbsfleet Garden City and which are much more relevant to Hartley and Longfield."




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